Stormwater Capture: Identifying Stormwater Needs Without a (Capital) Plan

For the past several years, the Water Environment Federation 'Recommendations to Improve the Stormwater Program in the U.S.' included 'Improve[ing] Stormwater Infrastructure Needs Data Collection.' The recommendation asks State Revolving Fund program managers to ensure that stormwater assets are included during Clean Watershed Needs Survey (CWNS) data to support advocacy for increased stormwater funding. Historically, less than half of states have reported stormwater asset needs in the CWNS. Today, few communities conduct proactive condition assessment and comprehensive master planning for stormwater systems and lack an understanding of long-term compliance costs. For stormwater needs to receive national recognition, program managers need to understand the condition of their assets, short and long-term costs, and the staffing and labor necessary to sustain their programs. If we can't clearly define our infrastructure, resiliency, compliance, and planning needs, we can't expect to get critical funding for it. In 2022, the EPA is conducting the next round of CWNS. This is an important opportunity for stormwater programs. The states often relying on local wastewater utilities to generate documentation that meets EPA standards. To meet these standards, all documents must clearly define the NEED, the SOLUTION, and the COSTS of the solution. Typical wastewater supporting documents include Asset Management Plans, Intended Use Plans, various grant and loan applications, and Facility Plans, among others. Stormwater programs may have documents like Preliminary Design Reports for clean water obligations under Combined Sewer Overflow Long-Term Control Plans, Watershed Management Plans (name varies among states) for impaired waters with implementation cost estimates, grant or loan applications, or Stormwater Master Plans, among others. Many stormwater programs, however, do not have these more traditional engineering reports or capital. EPA has suggested that alternative documentation is permittable, if approved by the agency. This presentation will provide an overview of alternative documentation approaches considered in EPA Region 1, the documentation generated for stormwater needs, and a detailed overview of the approach taken with the state CWNS coordinators. It will complement the EPA CWNS update proposed in an abstract from the EPA National Office, providing additional details on alternative documentation. It could be set up as part of a panel discussion suggested by NMSA on the future of the CWNS and how the stormwater community can better position for future needs documentation.